State v. Johnson
In State v. Johnson, 930 P.2d 358 (Wyo. 1996), the prosecution introduced co-defendant statements made during sentencing.
The Court found that the statements were reliable because:
(1) the declarant and the defendant were friends;
(2) the declarant had no apparent reason to lie in his statements;
(3) the statements were voluntary;
(4) the statements were consistent over time. Johnson, 930 P.2d at 368.